The Campaign to Protect Rural Essex (CPREssex) is the county branch of the Campaign to Protect Rural England, which has 50,000 members. It exists to promote the beauty, tranquillity and diversity of rural Essex by encouraging the sustainable use of land and other natural resources in town and country.

Planning application UTT/0717/06/FUL

Applicant: BAA plc and Stansted Airport Ltd

In response to additional information from BAA further to UDC Regulation 19 Notice and other UDC requests made on 15 September 2006

TABLE OF CONTENTS

1. Background

2. Comments on BAA’s R19 Responses

2.1 Landscape Character

2.2 Light Pollution

2. 3. Climate Change

2.4 Quality of Life

KEY

BAABritish Airports Authority

CPREssexCampaign to Protect Rural Essex

ESEnvironmental Statement

QoLAQuality of Life Assessment

SSEStop Stansted Expansion

UDCUttlesford District Council

1. Background

Our comments apply to BAA’s response on 27 September 2006, made publicly available on 6 October 2006, to UDC’s request on15 September 2006 for additional information. This followed BAA’s planning application UTT/0717/06/FUL for expanded use of its existing runway at Stansted Airport. It also applied to associated documents omitted at the time of the application but submitted later: (On 23 May 2006 BAA submitted a Sustainability Appraisal and on 6 June 2006, a Health Impact Assessment)

The Council's information request was set out in three schedules:

  • Schedule A – Further information required under Regulation 19
  • Schedule B – Additional substantive outstanding matters previously raised in the Scoping Opinion
  • Schedule C – Matters of clarification, explanation and detail.

CPREssex responded to the original application on 24 July 2006. We confined this to a few key issues of particular relevance and concern to CPRE. We noted that Stop Stansted Expansion (SSE), with whom we collaborate on responses such as these had responded in considerable depth on other factors in the BAA’s submissions and that we fully supported SSE’s comments and assessments and saw little purpose in repeating them.

We further note that SSE has also submitted detailed comments on BAA’s Regulation 19 (R19) response, containing much adverse comment fully supported by analysis. Again we see no purpose in repeating this here.

We note that some issues are not referred to at all in BAA’s response or in SSE’s commentary. If this is because they were omitted from UDC’s requests (Schedules A thro’ C above) we must note that we think it wrong that BAA should be allowed to evade responsibility for answering any concern that individuals or organisations have on the impact of its proposal on environmental factors and Quality of Life.

2. Comments on BAA’s R19 Responses

2.1 Landscape Character

BAA makes no reference to the impact on landscape character. We refer the council to our original response[1]. CPRE has recently completed a major research project on tranquillity mapping in England, launched nationally late in October. Tranquillity is one of the most important things the countryside can give us. It distinguishes the countryside from cities. It can both inspire and calm us. It helps us ‘get away from it all'. Sadly, tranquillity isn’t so easy to find anymore. Aircraft, roads and road traffic and excessive development are eating inexorably into tranquil areas or diminishing an area’s level of tranquillity. Expansion of activity at Stansted to 35mppa and above can only inflict a further step-change in damage to tranquillity in the district of Uttlesford and beyond.

Hatfield Forest is a Site of Special Scientific Interest (SSSI). The National Trust has drawn attention to damage by Nitrogen Oxides and to how this is likely to be exacerbated by further increased aviation activity. We note that SSE’s analysis of BAA’s response draws attention to continued absence of a study that BAA was required to make, formalised over three years ago in the Section 106 agreement of May 2003. The results of the study should have been reported either before or concurrent with the current planning application. The continued inadequacy of BAA’s commitment to issues such as this should not continue to be accepted. No doubt the National Trust will pursue this matter.

2.2 Light Pollution

This important environmental factor is mentioned only in context of UDC’s request for BAA to complete the ‘base line study of current condition of flora and fauna within Hatfield Forest, East End Wood and fen site and study of the effects of noise air and light pollution on these sites’ (Schedule A Para 2.1 UDC Requirement 1). We refer to our original response on light pollution to BAA’s Application.[2]

2. 3. Climate Change

CPREssex reiterates its earlier statement that

“tackling the problem of global warming is fundamental to achieving sustainable development. It seems to us that allowing an increase in aircraft movements with the consequent increase in harmful emissions is contrary to achieving sustainable development. Aircraft emissions are particularly damaging as they are released at high altitude and have thereby greater adverse impact. (At least 2.5 times more damaging for each kilogramme of CO2 released according to the Royal Commission on Environmental Pollution[3], rising to 4.1 times if the cirrus cloud effect is included.)”

This being so, and the message having been driven home since we wrote these words by such as the Stern Report[4],it is quite disgraceful that BAA continues to avoid answering questions put to it on CO2 emissions.

We can only concur with SSE’s comment[5]:

“BAA’s continued refusal to respond to UDC’s request for information regarding CO2 emissions can only be because it does not wish to disclose the scale of emissions from aircraft operations at Stansted and risk triggering a wider debate which it anticipates could cause difficulties for its planning application.”

“BAA's position in refusing to provide this information is both untenable and pointless. In the absence of this information, it would be impossible for UDC even to consider granting planning approval for the proposed development. The Council has an obligation to consider all the relevant environmental impacts and it can hardly be argued that CO2 emissions are irrelevant when aviation is the fastest growing cause of CO2 emissions and Stansted is the fastest growing major airport in Europe.”

2.4 Quality of Life

BAA’scontinued refusal to submit a Quality of Life Assessment (QoLA) – P7 Para 2.2.1 - demonstrates an arrogant disregard for UDC and the people of Uttlesford and the surrounding area.

BAA goes on to argue (P5 and P6 Para’s 2.2.5 thro’ 2.2.10) that material contained in its Environmental Statement, Sustainability Appraisal, Health Impact Assessment and elsewhere “constitutes a substantial body of information giving guidance on the effects of the application on indicators typically used within Quality of Life Assessments.” In other words, “here is a kit of parts that you, the people whose lives are to be impacted by what we want to do, may be able to use to build your own QoLA”

CPREssex regards this as an unreasonable, in fact disgraceful, response to a fundamental issue. BAA also attempts (P4 Para 2.2.1) to hide behind the claim that it is under no statutory requirement to produce a QoLA in spite of the fact that UDC has specifically asked for one.

The process of preparing a QoLA is not one of extracting various items of data from a text and making some sort of subjective evaluation. There is a methodology in which the assessment emerging from the process has a value in its own right that is greater than the mere sum of the parts (the separate data items). It is this that BAA is clearly afraid to carry out and present.

As Levett-Therivel has explained[6]

“QoLA focuses on the benefits and services provided by an area (e.g. tranquility, informal outdoor recreation, carbon fixing). Benefits ‘look’ different from the impacts assessed in EIA: they are related to how people value their neighborhood, not the things that are in the neighborhood. As its name suggests, QoLA assesses the potential impact of a development on the quality of life of the people potentially affected by it. What benefits matter, and therefore what indicators may be appropriate to measure them, are identified during the process. You therefore can’t say what indicators might be relevant to a QoLA assessment of a particular project until you have done the process.”

Pointers to why BAA is so reticent to provide the QoLA requested can be seen in paras 2.2.12 and 2.2.14, pages 6 and 7 of its R19 Response. BAA says:

“For this [QoL] sub-indicator [parks and open spaces] STAL suggests that the effects of the proposed development due to increased aircraft movements might give rise to some additional visual intrusion and noise. It is not however anticipated that such effects would be significant” (Para 2.2.12, P6)

and:

“Certain effects of the proposed development would, however affect QoL in both positive and negative ways and to a large extent would depend on the area of study. For example the Generation 1 development would, as acknowledged in the Generation 1 ES, lead to an increase in the number of people being exposed to higher noise levels recognised to cause annoyance. There would also be more road traffic and small changes in local air quality. Equally the proposed development, as well as providing much needed capacity to meet people’s desire to travel would bring with it employment opportunities and improvements to transport facilities and services as well as supporting economic growth and national prosperity which in itself must lead to improved quality of life.” (Para 2.2.14, P7)

The ‘might’, above, can almost certainly re read as ‘will’.

If any of the above means anything at all the negatives and positives should be quantified. BAA can in no way flippantly anticipate that an effect would not be significant.

But some negatives are at least acknowledged, although what a “small” change in air quality is BAA does not tell us. How much impact it would have requires the conduct of a QoLA.

Consideration of the so-called ‘positives’ reveals that they are not to be accepted at face value.

(a)“Much-needed capacity to meet people’s desire to travel”.

There is plenty of current capacity. Growth in aviation activity on the scale BAA proposes in this application is in fact a huge negative in its potential contribution to climate change.

(b)“Would bring with it employment opportunities”.

In its response to the original planning application[7], based on BAA’s statements and SSE own research, SSE concluded:

  • We assess the economic, employment and housing impacts to be "very high adverse" at the local level, "high adverse" at regional level and "adverse" at national level.
  • The development would give rise to local over-dependency on airport jobs and would run counter to the Council's policy objectives.
  • The proposed development would have significant displacement employment impacts in relation to the regional and national tourism industry.
  • It would make Uttlesford District a less attractive location for inward investment of a type which could bring greater economic and employment diversity to the district;
  • The type of jobs that would be created would be predominantly of an unskilled and low-skilled nature and do not fit well with the inventory of skills and qualifications in the local labour market.
  • The development would have significant adverse implications for the United Kingdom balance of payments as a consequence of the tourism trade deficit arising from Stansted Airport's focus on leisure travel, particularly catering for outbound tourism.

© “Would bring improvements to transport facilities and services”

Assuming BAA is referring to public road and rail services, the evidence is to the contrary. CPREssex drew attention to surface access problems in our response to the original application[8]. SSE was also very critical.

More recently a CAA report published 9 November 2006 showed that half a million fewer airport passengers used the train to get to and from Stansted Airport last year compared to 2004. Just 4.8 million airport passengers used the train to access Stansted Airport in 2005 compared to 5.3 million in 2004, despite an overall 5 percent increase in the number of passengers using the airport. Almost three quarters of Stansted passengers (74.6%) now use the roads to access the airport and only a quarter (25.0%) use the rail service, down from 28.8% in 2004.

BAA's increasing reliance upon road rather than rail travel at Stansted is directly contradictory to the Government's policy which calls for a "radical change in transport policy" based on reduced dependence on the car and greater emphasis on public transport. Government policy makes clear that airport operators, such as BAA, are expected to play a full part in achieving this. At Stansted however, the proportion of passengers travelling by rail has been declining over the past five years.

All of the above supports the conclusion that BAA’s flouting of legitimate and proper requests for a Quality of Life Assessment – the fundamental criterion, in tandem with climate change impact to be applied to BAA’s application– arises from its recognition of the damage a full QoLA would do to its application.

BAA cannot be allowed to continue to get away with this, especially now that its defiance is in relation to a formal Regulation 19 Notice.

We repeat what we said in our original response to the BAA’s planning application.

“If the applicant remains unwilling to provide this information [a QoLA] your council could consider the lack of it as one ground for refusal.” [9]

Page 1 of 6

[1] Campaign to Protect Rural Essex; Response to Planning Application UTT/0717/FUL; 24 July 2006 Item, 2 P1

[2] Campaign to Protect Rural Essex; Response to Planning Application UTT/0717/FUL; 24 July 2006 Item, 9 P4

[3] Royal Commission on Environmental Pollution: Environmental Effects of Civil Aircraft in Flight; 2002

[4] Sir Nicholas Stern: Review on the Economics of Climate Change, Report to the Prime Minister and Chancellor of the Exchequer 30 October 2006

[5]Response on behalf of Stop Stansted Expansion, Vol 3; 2 November 2006, p13 item 3.2.1 and p14 item 3.2.4

[6]'Environmental Statement for Stansted Generation 1: Analysis of Strategic Issues', Levett-Therivel, June 2006, Section 5, pages 17-18.

[7] Planning Application UTT/0717/06/FUL; Response on behalf of Stop Stansted Expansion, Vol 1 14 July 2006

[8] Campaign to Protect Rural Essex; Response to Planning Application UTT/0717/FUL; 24 July 2006 Item 6, P3

[9]A recent case was reported in Planning Newspaper on 14 July 2006 (P19 Ref DCS No. 100042762) where non-provision of information by an applicant was considered a valid reason for refusal.